Different Sources of Income Matter FDAP v. ECI One of the issues difficult for some of my international clients to grasp about the United States is its taxation of citizens and resident aliens alike on their worldwide income without any regard to where the income is...
Do you get paid to entertain or support an entertainer or entertainment operation?...
This is really confusing folks! On the one hand those of us who follow closely generally tend to believe that there is a LOT of rampant fraud in SSI Disability benefits practices these days but this news is going to really hurt a LOT of...
UGH! I vowed to stop writing about the tax implications of marijuana taxation: Beck v. Commissioner & Excise Tax Paid. The catholic guilt of a dysfunctional adolescence must be burning deep today as resisting the urge to come back for yet another round of punishment is...
IRS Form 8833 - Treaty-Based Return Disclosure Under IRC 6114 - When MUST It Be Filed? While the light of my life was off at a family wedding in Fargo, ND this past weekend a friend flew into town unexpectedly from Minnesota with a complimentary ticket...
In Coca Cola's SEC 8-K filing last week we learned that the IRS issued a $3.3 Billion statutory notice of deficiency against the company as the result of a 5 year long transfer pricing audit covering tax years 2007-09. This is very BIG when it comes to enforcement of IRC...
U.S. competent authority assistance is not necessarily contingent upon whether you sign an agreement with the IRS Examination function contrary to the assertions of some IRS Revenue Agents. Turns out this is important information for some US Taxpayers of international origin in battle with the IRS. Yes...
Aside from this tax blog the following are the most useful resources for researching Individual Taxpayer Identification Number (ITIN) application processing. IRS Publication 1915 General ITIN Information page Update to the Instructions for Form W-7 and ITIN Processing Time IRS Rev Proc 2006-10 IRS Form W-7 IRS Form W-7 Instructions If you...
If you do not have a Social Security Number (SSN) and are not eligible to obtain a SSN, but you are required to provide a tax identification number (TIN) to file a U.S. Federal income tax return, be claimed as a spouse or dependent on...
I personally believe that it is in EVERYONE'S best interest for all people materially present in the USA to be here LEGALLY. I also believe that the US Federal government has an obligation to do a much better job of helping people legally be present,...